Constellation Brands, Inc Global Online Privacy Policy

Effective November 1, 2017

This Privacy Policy describes how TRU Estates and Vineyards, Constellation Brands, Inc. and its subsidiaries and affiliates (collectively, "we," "our" or "us”) collect, use and disclose information about visitors and users (collectively, "users") of our websites, online features, products and services that link to this Privacy Policy (each a "Site" or collectively, "our Sites"). You can identify the brand that hosts a particular Site through the Site's footer or "About" link. By visiting or using our Sites, you consent to us gathering and processing information about you in accordance with this Privacy Policy.

Information we collect and receive about you

By visiting or using our Sites, we may collect the following categories of personal information ("Personal Information") you provide to us:

Birthdate;

Name;

Email address;

Telephone number;

Mailing address;

Credit card number and payment information;

Username and password; and

Any other Personal Information you volunteer, including in the order notes, in relation to a promotion (including contests, sweepstakes, offers, and rebates) or survey, or on any of our community forums, social media offerings or blogs.

We may from time to time request you post comments and images from your social media account(s) (including, but not limited to, Instagram, Twitter and Facebook) with certain hashtags. In certain instances, if you add those hashtags to your image, depending upon your social media privacy settings, the image may be redisplayed on our Sites. While you retain ownership of the image, using the hashtags we request gives us permission to display and re-display the image. The image may contain information about you, and we may collect and use that information for marketing and research purposes. If you do not want your image posted on our Sites, please do not use our requested hashtags.

In addition, we may receive certain categories of Personal Information listed above from sources other than you, such as from our business partners and third-party applications (including, but not limited to, Instagram, Twitter and Facebook) that you use in conjunction with this Site (e.g., for age-gating purposes).

We may also automatically collect the following categories of information from devices (e.g., mobile, computer, laptop, tablet) used to visit or use our Sites ("Device Information"):

IP address;

Device identifier;

The website you visited before our Site;

Browser type;

Any search terms entered on our Site;

General location data based on your Device Information, such as country, state or province;

Computer operating system;

Access times;

Usage patterns and page views within our Site;

Log files;

Cookies;

Clear gifs; and

Flash LSOs.

Personal Information and Device Information are collectively referred to as "information."

We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy and as otherwise needed to comply with applicable law and internal company policies.

How We Use Your Information

We may use the information we collect from you to:

Provide you with information, services and products offered on our Sites;

Respond to or follow-up on your comments, inquiries, or other requests;

Communicate with you about your account or use of our Sites;

Improve the quality of our Sites, services and products, and tailor them to your preferences;

Implement social networking features you have activated (e.g., Facebook "Like" button); and

Communicate with you about special offers and other marketing communications.

We also use your birthdate to verify that you are of legal drinking age, as we are in the business of selling alcoholic beverage products.

In addition, we use your information for compliance with our company policies and procedures, for accounting and financial purposes, and as otherwise consented to by you and as required or permitted by law. If you do not provide us with information as described above, we may not be able to fulfill the applicable purpose of collection, such as to respond to your queries or provide our Sites to you.

How We Share Your Information

From time to time, we may share your information with our affiliates, subsidiaries, business partners, third party service providers and authorities in the following circumstances:

Our Affiliates, Subsidiaries and Business Partners. We may share your information with our affiliates, subsidiaries and business partners in the US and worldwide for the purposes described above and for other general business administration purposes. By visiting or using our Sites or otherwise providing us with your information, you consent to this transfer of your information throughout our network of entities. To opt-out of such disclosures, please see the "Choice" section below.

Service Providers. We may share your information with third parties who perform functions on our behalf (e.g., hosting or operating our Sites, processing credit card payments, sending email marketing communications, processing job applications, data analysis and other business support services). We do not authorize these third parties to use your information for purposes other than for which it was provided, and do not authorize these third parties to disclose that information to unauthorized parties. We require these third parties to maintain appropriate security to protect your information from unauthorized access or processing.

As Required or Appropriate by Law. We may disclose your information to regulatory authorities, courts, government agencies and other third parties where we believe that doing so would be in accordance with or permitted or required by any applicable law, regulation or legal process, to defend the interests, rights, and/or property of us or others, or to respond to emergencies.

Business Transfers. We may transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

In addition to the above circumstances, we may share your information with other parties as directed by you or subject to your consent. We may also share and otherwise process aggregated information or de-identified information that does not identify you individually with other parties. For example, we may share aggregated statistics about pages viewed on our Sites, demographic information and sales, and other shopping information with third parties to enrich your visitor experience.

Cookies and Similar Technologies

When you use our Sites, we along with our affiliates, subsidiaries and third-party service providers may use "cookies" and similar technologies (e.g., beacons, log files, pixels and Flash LSOs) (collectively, "technology"). This technology involves placing small files/code on your device or browser that serve a number of purposes, such as remembering your preferences (e.g., language) and generally improving your experience on our Sites. Specifically, we may use such technology for purposes such as to:

Provide us with general analytics about our Sites, including demographic information in a non-identifiable form, in order to improve our Sites' performance and customize users' experience;

Support security measures, such as requiring re-login into your account;

Allow you to engage in our social media offerings on our Sites (e.g., Facebook "Like" button); and

More effectively market our Sites and advertise other Sites that may be of interest to you.

Where required by law, we collect your consent for the use of such technologies.

Cookies. A cookie is a small text file saved on your device or browser. Some of these cookies are necessary for the functioning of our Sites (known as "Strictly Necessary" cookies), while others are not (known as "Non-Essential" cookies). Some cookies (known as "persistent cookies") will remain on your device until you delete them, while others (known as "session cookies") are automatically erased when you exit your Internet browser.

You can set your device or browser to accept or reject most cookies, or to notify you in most situations that a cookie is offered so that you can decide whether to accept it. However, if you block cookies, certain features on our Sites may not function. Additionally, even if you block or delete Cookies, not all tracking will necessarily stop.

We may place or recognize technology on your browser or device when you visit our Sites for purposes of serving you targeted advertising (also referred to as "online behavioral advertising"). We also work with third party advertising companies who place their own cookies or similar technology on your browser or device when you visit our Sites and other websites to serve customized advertisements to you as you browse the Internet. As noted above, you can set your device or browser to accept or reject most cookies, or at least notify you in most situations that the technology is offered. As an additional step, these advertising companies may participate in one of the following self-regulatory programs for online behavioral advertising, with corresponding user opt-outs:

Clear Gifs (Web Beacons/Web Bugs/Embedded Pixels). Clear Gifs are embedded on our Sites and are about the size of the period at the end of this sentence. The information collected by these technologies is associated with other technology and information, but only for internal tracking purposes only.

Flash LSOs. Flash Local Storage Objects ("Flash LSOs"/"Flash Cookies") display content based upon your preferences for how you like to view our Sites. Flash LSOs are different from browser cookies because of the amount of, type of, and how information is stored. Cookie management tools provided by your browser will not remove Flash LSOs. To learn how to manage privacy and storage settings for Flash LSOs, click here.

Third party applications and APIs. We also offer and deliver services, content or interactive features through and/or using third party application programming interfaces, gadgets, and/or extensions that are hosted on our Sites or through other third-party websites or social networking platforms. When you use these services, content, or interactive features, or otherwise connect with, or "accept" or "allow" third party applications, networks, platforms or services through our Sites, you are authorizing those third parties to receive your information and additionally to potentially share any or all of your information with us, based on your privacy or other settings on the particular third-party network or platform. Any information we receive by these means will be treated and/or processed according to this Privacy Policy.

Choice

Email. If you no longer wish to receive email marketing communications from us, you may opt-out of receiving marketing-related emails by using the unsubscribe method provided in our communications (e.g., by clicking on the "unsubscribe" link in the email to unsubscribe). Alternatively, to the extent that applicable law requires your prior opt-in consent to receive marketing and promotional emails, we will ask for your consent and you can choose not to opt-in.

Text Message. If you no longer want to receive text messages from us, reply STOP (or as otherwise instructed) in the text message. Alternatively, to the extent that applicable law requires your prior opt-in consent to receive text messages, we will ask for your consent and you can choose not to opt-in.

Cookie Choices. To exercise choices regarding cookies set through our Sites, as well as other types of online tracking and interest-based advertising, see the "Cookies and Similar Technologies" section above.

In addition to the above methods of exercising choice, to the extent required by applicable law, we also provide you the ability to opt out of sharing your information with certain third parties for their own use by contacting us as detailed in the "Contact Us" section below. You may also send requests about your contact preferences related to the items listed above or changes to your information to us as detailed in the "Contact Us" section below.

We will try to comply with your request as soon as reasonably practicable as required by applicable law. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. In addition, please note that even if you opt-out of receiving marketing communications from one or all of our Sites, we may need to send you service-related communications and may need to keep information we have collected about you for record-keeping, research, and other purposes.

Access and Correction of Your Information

If you have created an online account with us and would like to update the information you have provided to us, you can access your account to view and make changes or corrections to your information. Depending on applicable law, you may have the right, and we also provide you with the opportunity to be informed of whether we are processing your information and to access, correct, update, oppose, delete, block, limit or object, upon request and free of charge, to our use of your information to the extent required by applicable law. For such inquiries, please contact us as detailed under the "Contact Us" heading below. We will try to comply with your request as soon as reasonably practicable as required by applicable law. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law.

Security of Your Information

We take commercially-reasonable technical, administrative, and physical security measures to protect your information, including generally accepted industry standards to protect the information submitted to us during transmission and once we receive it. When you provide us sensitive information (e.g., credit card number), we encrypt that information using secure socket layer technology ("SSL") or similar technology. However, no method of transmission over the Internet, or method of electronic storage is 100% secure, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed under the "Contact Us" heading below.

International Transfers

Some of the parties identified above may be located in countries that do not provide an equivalent level of protection as your home country. Where required, we have taken appropriate measures to allow and secure the transfer of information about you to these recipients for the purposes described above and in order to comply with local data privacy laws. By using some of our Sites, and providing us information about you, you consent to the international transfer of information about you to the above parties.

Links to Other Websites

Our Sites may contain links to other websites or services that are not owned or controlled by us, including but not limited to links to websites of our advertisers, sponsors, and partners. This Privacy Policy only applies to information collected by our Sites. We have no control over these third-party websites, and your use of third party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Sites. Your use of third parties' websites linked to our Sites is at your own risk, so we encourage you to read the privacy policies of any linked third-party websites when you leave one of our Sites.

No Data Collected from Children/Minors/Those Under the Legal Drinking Age

Our Sites are intended only for those of legal drinking age and we do not knowingly collect information from individuals under the legal drinking age, children or minors.

California Residents - Your California Privacy Rights

As described in this Privacy Policy, we may share your Personal Information with third parties for such parties' direct marketing purposes. Under California's "Shine the Light" law, if you are a California resident who provides Personal Information in obtaining products or services for personal, family, or household use, you may request to opt-out of such sharing by a brand at no-cost by following the instructions in the "Choice" section above, or by contacting us as detailed in the "Contact Us" section below. Please be aware that your opt-out will apply only to the sharing by that particular brand.

Changes to this Privacy Policy

Except to the extent limited by applicable law, we reserve the right to update this Privacy Policy to reflect changes to our information practices by prominently posting notice of the update on our Sites. Any updates will become effective immediately after posting the updates to the Privacy Policy and apply to all information collected about you. If we make any changes to this Privacy Policy that materially impact previously collected information about you, we will, to the extent that we have your email address, notify you by email.

Contact Us

If you have any questions about this Privacy Policy or information we have collected about you, please contact us online here, by email at privacy@cbrands.com or by postal mail at: